, 331 Or
335, 344-45, 15 P3d 22 (2000). Rather, defendant argued that the officers lacked
sufficient evidence that he presented an immediate threat to their safety. Defendant
renews that argument on appeal, and we turn to it.

The state, for its part, does not dispute that Blackman stopped defendant
when he took hold of defendant's arm and pulled him into the house, and the state does
not argue that Blackman stopped defendant because he reasonably suspected that
defendant had committed or was about to commit a crime. Rather, the state relies solely
on the officer safety doctrine to justify Blackman's actions. On that point, the court
explained in State v. Bates, 304 Or 519, 524, 747 P2d 991 (1987):

"Article I, section 9, of the Oregon Constitution, does not forbid an officer
to take reasonable steps to protect himself [or herself] or others, if, during
the course of a lawful encounter with a citizen, the officer develops a
reasonable suspicion, based upon specific and articulable facts, that the
citizen might pose an immediate threat of serious physical injury to the
officer or to others then present."

As a rule, generalized concerns about officer safety are not sufficient to justify invading a
person's constitutional rights. State v. Cocke, 334 Or 1, 10, 45 P3d 109 (2002); Bates,
304 Or at 526; State v. Walker, 181 Or App 548, 552, 47 P3d 65 (2002). Rather, the state
ordinarily must identify something specific about the particular defendant that reasonably
gives rise to the concern that he or she might pose an immediate threat of serious physical
injury. Bates, 304 Or at 526-27.

We have twice considered whether officer safety concerns permit police
officers executing a search warrant to seize persons who are present but not named in the
warrant. See State v. Reinhardt, 140 Or App 557, 916 P2d 313 (1996), rev dismissed as
improvidently allowed 327 Or 521 (1998); State v. Barnett, 132 Or App 520, 888 P2d
1064, rev den 321 Or 137 (1995). In Barnett, the officers executed a warrant on the
Cosgrove residence. 132 Or App at 522. They knew that Cosgrove frequently used
methamphetamine and was paranoid. Id. They also knew that Cosgrove kept firearms in
the house and was likely to use them. Id. When the officers executed the warrant, they
quickly entered the house, placed Cosgrove, his wife, and the defendant (a visitor) on the
floor and handcuffed all of them. Id. We explained that "[i]t was not unreasonable for
the officers to fear that, in the confined space of the Cosgroves' living room, the putative
weapons would be readily accessible to any occupant, including a visitor." Id. at 524.
We held that officer safety concerns justified handcuffing the defendant even though
there was no evidence about the defendant, other than his presence in the Cosgroves'
home, to suggest that he would be likely to use any available weapons against the
officers. Id.

In Reinhardt, the officers executed a search warrant at a house in which
stolen property was exchanged for methamphetamine. 140 Or App at 559. People
visiting the house, and perhaps those occupying it, were "biker type people." Id. At some
point in a two-month period before the warrant was executed, someone was seen in the
house carrying a gun. Id. at 563. When the officers entered the house to execute the
warrant, they saw the defendant standing near the living room wearing a "black
'motorcycle-type' jacket and black boots." Id. at 559. The officers ordered the defendant
to get on the floor and handcuffed him. Id. We declined to assume, based solely on the
defendant's clothing, that he was dangerous. Id. at 562-63. We also distinguished
Barnett on the ground that "there [wa]s no evidence that firearms were readily available
to any occupant of the house. Likewise, there is no indication that the owner of the house
was armed and dangerous." Id. at 564. We noted that the only evidence that firearms
might be available to any of the occupants of the house was a statement that someone at
some point in the previous two months had been seen with a firearm. Id. Given that
evidence, we held that the state had failed to present sufficient specific and articulable
facts that the defendant might pose an immediate threat of serious physical injury.

In this case, the officers entered Ness's house in the morning to execute the
warrant. Defendant did not arrive until sometime in the afternoon. By that time, the
officers had secured control over both the house and the people inside it. The officers
were not aware of any unsecured weapons in the house or other comparable
circumstances, nor did they have any specific information that the people coming to the
house would pose a danger to them. The officers' legitimate need to determine who is
present and whether those persons pose a risk to them when they first execute a warrant--the concern that drove our opinion in Barnett--is absent here.

The second distinction is related to the first. The officers legitimately could
infer from Ness's surveillance system and his occupation that he presented a danger to the
officers executing the warrant. Not only do surveillance systems give drug dealers an
advantage over the officers' seeking entry, but the officers reasonably could have inferred
that Ness would use that surveillance system to their disadvantage when they attempted to
enter his home. After the officers successfully entered the home, however, any advantage
provided by the surveillance system disappeared. More importantly, even though the
officers could infer from the surveillance system and Ness's narcotics business that Ness
would resort to violence to prevent others from entering his home, those facts say nothing
about whether other persons coming to Ness's home would also be likely to resort to
violent behavior.

Third, the officers did not identify anything specifically about defendant
that suggested that he might present a threat to their safety other than the fact that he came
to the front door of Ness's house and was trying to look inside through the glass door.
One of the officers testified that the officers' safety concerns are not limited to entering a
home. Rather, they continue while the officers execute the warrant because "if somebody
comes in with a firearm, multiple people could be injured or killed." However, nothing in
this record suggests that defendant had a firearm or any other weapon when he came to
Ness's house.

Officers legitimately will be concerned about persons coming to a house
while they are conducting a search. Blackman, however, could have spoken with
defendant outside the house without pulling him in. See United States v. Clay, 640 F2d
157, 161 (8th Cir 1981). He could have turned defendant away instead of pulling him in
if he had some unspecified and unarticulable concern that defendant might be dangerous.
See id. Blackman, however, did not articulate anything about defendant or the
circumstances of the case that required him to pull defendant into the house for officer
safety concerns. We do not suggest that officers must take the least intrusive course
available to them in order to come within the officer safety doctrine. Rather, we measure
their actions by a test of reasonableness. See Barnett, 132 Or App at 524. But, on these
facts, some more specific evidence that defendant posed a risk of harm to the officers was
necessary before they could take hold of him and pull him into the house. Bates, 304 Or
at 526; State v. Dyer, 157 Or App 326, 332-33, 970 P2d 249 (1998). Because the
subsequent frisk and search incident to arrest were the product of that unconstitutional
act, the evidence the officers found should have been suppressed.

Reversed and remanded.

1. Defendant does not argue on appeal that the officers acted unlawfully when
they opened the elongated oval container they found in his pocket during the pat-down
search, nor does he challenge the later search of his bag. Rather, he argues that that
evidence should be suppressed as the fruit of either the stop or the frisk.

2. Before the trial court, defendant argued that the stop was not justified either
by a reasonable suspicion that he committed a crime or by officer safety concerns. He did
not argue, as he now does, that a stop is justified only if the officer reasonably suspected
that he had committed or was about to commit a crime.

3. Of course, as the court held in Cocke, the officer safety doctrine does not
permit an officer to enter a separate residence without some showing that the persons in
that separate residence might pose an immediate threat of serious physical injury to the
officers. 334 Or at 9-10.

5. The requirement that officers knock and announce has been explained on
the ground that it protects "the safety of the officers and the others on the scene against
violent consequences of a sudden, unexplained break-in." State v. Davis, 295 Or 227,
236, 666 P2d 802 (1983). Conversely, the courts have recognized an exception to that
rule when notice will increase rather than decrease the risk of harm that entry poses to the
officers. Ford, 310 Or at 634-37; see Model Code of Pre-Arraignment Procedure 514
(1975). Significantly, as these cases demonstrate, the courts have uniformly recognized
that the act of entering a home to execute a warrant places officers at greatest risk.